• Public Ruling 1/2022 Time limit on unabsorbed adjusted business losses carry forward (> IRB first public ruling in 2022)
  • Effective year of assessment 2019, unabsorbed adjusted business losses carried forward for a period of 7 consecutive years of assessment
  • The time limit for unabsorbed adjusted business losses carried forward arising from a relevant year of assessment change from a 7 consecutive years of assessment to 10 consecutive years of assessment …
  • … through the Finance Act 2021 [Act 833] effective year of assessment 2019.
  • Any balance of unabsorbed adjusted business losses after the end of the period of 10 consecutive years of assessment is to be disregarded (ie lost)
  • T&C, There has been no substantial change in the company’s shareholding
  • Compare the last day of last YA and the first day of next YA on shareholding.
  • More then 50% of the nominal value of the allotted shares
  • More then 50% of the paid-up capital
  • Dormant company only
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